• Whether you're currently living in Europe, are a European citizen or are thinking about moving to the area, European succession laws might effect you and your life, and the European laws are very different from succession and estate laws in the United States. Succession laws regulate who inherits a person's estate or property and can even supersede a person's stated wishes in Europe.
  
  

Jurisdiction

• Since the European Union was formed, rules regarding jurisdiction of an estate have become key in succession debates. In most cases, jurisdiction of an estate or property and the estate's succession falls under the laws of the deceased individual's home country or nationality at the time of death. If you're an English citizen living in Germany, the succession and division of your property is based on English law, not Geman law. If you become a German citizen; then German law applies. In other countries, such as France, French law applies as long as you're a habitual resident of the country, so if your primary residence is in France, French law applies no matter your nationality.
  
  

Reserved Portions

• In many European countries a portion of the estate is automatically reserved for a particular heir or heirs. The forced heir or legal heirs with reserved portions typically include a spouse or any children the deceased might have. Reserved portions can include up to one-third or half of the estate, depending on the European country. Reserved portions are deducted from the estate before the will comes into play. In other words, the reserved portions guaranteed to heirs by the law supersede the preferences of the deceased.
  
  

Inheritance Issues

• In many countries, reserved portions of the estate are not set aside for the spouse, and the law often favors the rights of a child or children over a husband or wife. This can lead to lengthy legal battles. Due to the reserved portions rule in some European countries, an estranged child could legally inherit a house and take it from a surviving spouse, depending on what was included in the estate. Unlike in the United States, in many European countries, you cannot leave your entire estate to your spouse in your will and have them actually receive it.